CT Torres Enterprises v. Hon.

Hibionada
GR No 80916. 9 November 1990
Quasi Judicial

FACTS
CTTE, as agent of Pleasantville Development Corporation, sold a subdivision lot to Efren
Diongon.
o After completion of payment, Efren demanded delivery of the title and when it
was not delivered, he filed a complaint for specific performance + damages
against CTTE and PDC.
After it was set for initial hearing, CTTE filed a motion to dismiss for lack of jurisdiction,
contending that the competent body was HLURB.
o Trial court denied motion: issue is contracts under the Civil Code, the jurisdiction
over which is granted to trial court under BP 129.

ISSUE + RULING
Does the issue at hand come under the jurisdiction of HLURB? YES.
Trial court failed to consider PD 1344, etc. and erred in supposing that only regular
courts can apply Civil Code provisions, to the exclusion of quasi-judicial bodies.
The Subdivision and Condominium Buyers Protective Decree, PD 957 provides that the
National Housing Authority has exclusive authority to regulate real estate trade and
business.
o Further, according to PD 1344, the exclusive jurisdiction over real estate cases
including cases involving specific performance of contractual and statutory
obligations filed by buyers of subdivision/condominium lots against the owner,
developer, broker, etc.
o Under EO 648, such regulatory functions were transferred to HLURB.
There are now hundreds of bodies adjudicating claims resoluble under the CC by virtue
of a valid authorization from legislature.
o This is called a quasi-judicial function and is exercised by them as an incident of
the principal power entrusted to them to regulate activities.
As a result of the growing complexity of the modern society, it has become necessary to
create more and more administrative bodies to help in the regulation of its ramified
activities.
o Specialized in the particular fields assigned to them, they can deal with the
problems thereof with more expertise and dispatch than can be expected from
the legislature or the courts of justice.